https://www.taxtmi.com/highlights?id=69975 Reopening of assessment u/s 147 - Addition u/s 68 - An alleged non-compliance of summons issued in some other years cannot be reckoned as 'failure on the part of assessee' and that too in some other assessment year. An enquiry was made in relation to share application money recd. while framing regular assessment of AY 2009-10 and assessment was framed taking note of outcome of such enquiry. Hence, mere reproduction of statutory language of first proviso would not meet the requirement of law for extension of limitation period beyond 4 years. - AT en-us Fri, 26 May 2023 17:22:09 +0530 Fri, 26 May 2023 17:22:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=69975 Reopening of assessment u/s 147 - Addition u/s 68 - An alleged non-compliance of summons issued in some other years cannot be reckoned as 'failure on the part of assessee' and that too in some other assessment year. An enquiry was made in relation to share application money recd. while framing regular assessment of AY 2009-10 and assessment was framed taking note of outcome of such enquiry. Hence, mere reproduction of statutory language of first proviso would not meet the requirement of law for extension of limitation period beyond 4 years. - AT Highlights Income Tax Fri, 26 May 2023 17:22:09 +0530 https://www.taxtmi.com/highlights?id=69975